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Responding to a request by a coalition of environmental, fishing and Tribal groups, the state and federal governments today extended the public comment period for the Draft Bay Delta Conservation Plan (BDCP) and the Draft Environmental Impact Review/Environmental Impact Statement (EIR/EIS) by 60 days.

The review period now totals 180 days stretching from Dec. 13, 2013 to June 13, 2014. "This extension will allow the public more time to review and comment on the public draft documents," according to an announcement from the California Natural Resources Agency.

“Keeping with our continued effort of transparency, additional time has been granted for review of the Draft BDCP documents facilitating greater public involvement,” said Secretary for Natural Resources John Laird. “All public comments received on the draft documents will be carefully evaluated and addressed in the Final EIR/EIS.”

The coalition had asked for a 120-day extension, twice the additional time granted by the state and federal agencies today.

Carolee Krieger, Executive Director of the California Water Impact Network (C-WIN), a member organization of the Environmental Water Caucus, said, “We thank them for the additional time, but this won’t change the fact that you can't produce more water by throwing money at it. The state has promised 5-1/2 times more water rights than the water that actually exists – and they can't get around that fact.”

"The additional time that we have been granted to respond to this is certainly welcome," commented Nick Di Croce, Co-Facilitator from the Environmental Water Caucus. "We are glad to see that the Department partially responded to our request; it now means that we have to review and comment on an average of only slightly more than 200 pages per day, including weekends. A 40,000 page EIR/EIS is truly an unworkable document under any circumstance."  

The Department announcement mentioned that "the 180-day comment period is four times that of the required 45 days in order to ensure the public has plenty of time to review the draft documents."

However, it did not mention that according to federal guidelines, a complex EIR/EIS should be no more than 300 pages, according to Di Croce.

The Environmental Water Caucus, a broad coalition of fishing groups, environmental organizations and Tribes, on December 19, 2013 sent a letter to federal and state agency officials asking for an 120 day extension in the public review and comment period for the Bay Delta Conservation Plan Draft Plan and EIR and EIS. (

The letter noted that the 40,214 actual pages of the document represent 20% more pages than the 32 volumes of the last printed edition of the Encyclopedia Britannica!

"You may recall that in a November 21 letter to you, prior to the December 13 release of the BDCP Draft Plan and EIR/EIS, we requested that the public review and comment period be extended beyond the planned 120 days, based on the anticipated 25,000 page estimate of the BDCP documents," wrote Di Croce, in the letter addressed to Samuel D. Rauch, Administrator for NOAA Fisheries Service, and five others.  

"We have now determined that there are 40,214 actual pages of the released documents and we request that you extend the public review and comment period for at least 120 additional days, due to the extraordinary size of the documents to be reviewed," he stated.

"Based on the dictated 120 day review time period, the public is being asked to review 473 pages of technical and scientific material per day during the 85 working days that are available during the public review and comment period. Additional time would be required to understand, research, and prepare comments on the voluminous documents," said Di Croce.

Caleen Sisk, Chief and Spiritual Leader of the Winnemem Wintu Tribe, pointed out the big impact that the Bay Delta Conservation Plan to build the peripheral tunnels will have on California Indian Tribes and Sacramento River Chinook salmon runs.

"These tunnels affect every Indian Tribe here in California as well as all salmon on the Pacific Coast," Sisk emphasized. "Every salmon fishing tribe should weigh in on this. These tunnels will KILL the Sacramento River salmon runs… all other runs will absorb the impact of thousands less salmon in the ocean!"

The Draft BDCP and associated Draft EIR/EIS are being made available to the public in accordance with the California Natural Community Conservation Planning Act, the Federal Endangered Species Act, the California Environmental Quality Act, and the National Environmental Policy Act.

The public review draft documents are available online at, and electronically at libraries throughout the state. Click herefor a full list of locations. If you would like to request a DVD copy of the documents please email

Comments must be received electronically or postmarked on or before June 13, 2014. Click herefor more information on how to submit comments.

Originally posted to Dan Bacher on Fri Feb 21, 2014 at 11:07 AM PST.

Also republished by California politics.

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